Prime Contractors to DHS - and Human Rights Policies
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ContractorHR Policy
Language Requiring Due Diligence
URLEmail Sent
Response Received
Follow-Up Sent
Response Received
Public Statements; Comments to News Outlets
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Accenture"We support and respect human rights throughout our operations as reflected by our longstanding commitment to the Ten Principles of the UN Global Compact" UNGC Lead Memberx
https://www.accenture.com/t20160908T034244__w__/us-en/_acnmedia/Accenture/next-gen/corporate-citizenship-report/documents/Accenture-2015-Corporate-Citizenship-Report.pdf#zoom=50
2/33/1
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AT&T"We are committed to respect basic human rights"
http://about.att.com/content/dam/csr/FAQpdfs/Human_Rights_Communications_Policy.pdf
2/33/1
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BAE Systems Intelligence & Security
"Our company is committed to respect human rights wherever we operate, within our sphere of influence."
http://www.baesystems.com/en-us/our-company/corporate-responsibility/working-responsibly/how-our-business-works/human-rights
2/33/1
3/1 "I have passed this query to our US Head Office and asked them to respond directly."
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Battelle National Biodefense Institute, LLC
None2/33/1
Survey request
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Boeing Company"Boeing is committed to the protection and advancement of human rights in its worldwide operations"
http://www.boeing.com/principles/human-rights.page
2/33/7
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Booz Allen HamiltonNone2/3
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CACI Federal, Inc."We support and defend the Constitution, and comply with the laws of the United States, ensuring that we carry out our mission in a manner that respects privacy, civil liberties and human rights obligations"2/3
2/6 "Thank you for your inquiry. Regret we can’t help you with your questions below but wish you the best with your report."
2/7
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Comprehensive Health Services, Inc. (CHSi)
none2/33/7
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Computer Sciences Corp. – $473 million
"CSC is committed to the protection and advancement of human right and to ensuring that our operations in communities around the world …"2/33/7
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Covenant Aviation Security, LLC
None2/33/7
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CSRA"We Observe Applicable Labor and Human Rights Laws"
https://www.csra.com/sites/default/files/csra-code-of-business-conduct.pdf
2/33/7
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Dell – $156 million"We are committed to ensuring that we are not complicit in any human rights violations and hold our suppliers and partners to this same high standard. Dell supports and respects the principles proclaimed in the Universal Declaration of Human Rights and believes businesses should ensure that they are not complicit in human rights abuses."x
http://www.dell.com/learn/us/en/vn/corp-comm/cr-report-human-rights-labor-policy
2/33/7
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Deloitte Services LP
"We support efforts to drive sustainable development and we respect human rights standards."
https://www2.deloitte.com/content/dam/Deloitte/global/Documents/About-Deloitte/gx-deloitte-global-principles-of-business-conduct-2016.pdf
2/33/7
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Ernst & Young LLPUNGC Principle 1: "• Businesses should support and respect the protection of internationally proclaimed human rights • Make sure that they are not complicit in human rights abuses"x
http://www.ey.com/Publication/vwLUAssets/United_Nations_Global_Compact_2015/$FILE/UNGC_Communication_on_Progress_2015.pdf
2/33/7
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FedExNone 2/63/7
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G4S Government Solutions
G4S is committed to fulfilling its responsibilities on human rights in all of its companies around the world by applying the United Nations Guiding Principles on Business and Human Rights (2011) across all of our businessesx
http://www.g4s.com/~/media/Files/Corporate%20Files/Group%20Policies/Human%20Rights%20Policy%20-%202.pdf
2/33/7
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General Dynamics Information Technology
General Dynamics is vigilant in preventing human rights violations. This is reflected in our corporation’s ethos—with our commitment to respecting the dignity, rights and autonomy of others—and reinforced through employment, ethics and procurement policies designed to ensure protection against human rights abuses, including human trafficking.
https://gdit.com/globalassets/gdit/pdf/partnerships/doing-business-with-gdit.pdf
2/33/7
No Answer http://www.newyorker.com/business/currency/the-tech-resistance-to-the-trump-refugee-ban
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Geo Group"GEO's implementation of its commitment to respect human rights is a process that requires ongoing assessment of its efforts, and continuous improvement." x
http://www.geogroup.com/Portals/0/SR/Human%20Rights/Human%20Rights%20Policy.pdf
2/33/7
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Grant Thornton, LLP
None2/33/7
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Harris IT Services"Harris, in collaboration with our Intermediaries and Suppliers, endeavors to achieve a leadership position in our markets through the adoption of responsible management practices related to business conduct, human rights, and the environment"
https://www.harris.com/sites/default/files/harris_sbc_intermediary_and_supplier_edition.pdf
2/33/7
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Herman Miller"All employees are required to… Adhere to international human rights conventions"
http://www.hermanmiller.com/about-us/who-is-herman-miller/legal/corporate-code-of-conduct.html
2/33/7
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HiltonThere seems to be a responsible sourcing policy, but Hilton's IR page is down right now. 2/63/7
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Holiday InnWe support and protect human rights wherever we can. As a responsible company with operations in nearly 100 countries and territories, we believe that strong ethics and good business go hand in hand and we are committed to complying with the laws and regulations of the countries and jurisdictions in which we operate.x
https://www.ihgplc.com/responsible-business/our-culture-of-responsible-business/human-rights, https://ihgplc-cdn.azureedge.net/-/media/AB5489EDEC5349EA82CFCFF30EBE6955.ashx?la=en&vs=1&d=20160714T142807Z
2/63/7
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HP Enterprise Services
"Our approach aligns with the UN Guiding Principles on Business and Human Rights and HP is a signatory to the UN Global Compact."x
http://www8.hp.com/us/en/hp-information/global-citizenship/society/humanrights.html
2/33/7
Amicus Brief Signatory;
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HyattIn keeping with this mission, we respect fundamental human rights, as embodied in the Universal Declaration of Human Rights. We believe that we have a responsibility to manage our business in a manner that is consistent with fundamental human rights and we attempt to foster similar ideals in those with whom we do business.
http://s2.q4cdn.com/278413729/files/doc_downloads/corp%20gov/HumanRightsStatement.pdf
2/63/7
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IBM US FederalUnderpinning our corporate responsibility standards and practices is our dedication to respect human rights. IBM's stance on human rights is informed by international standards, including the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the UN Universal Declaration of Human Rights.x
https://www.ibm.com/ibm/responsibility/ibm_humanrightsprinciples.html
2/63/7
http://gizmodo.com/ibm-remains-spineless-as-31-more-companies-oppose-trump-1792077171; http://gizmodo.com/ibm-remains-spineless-as-31-more-companies-oppose-trump-1792077171
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ICF InternationalNone2/33/7
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L3 "L-3 complies with all applicable laws and regulations, respects human rights, provides fair working conditions, and prohibits the use of any forced, compulsory, or child labor."
http://www.l-3com.com/sites/default/files/code-of-ethics/english/l-3_code_of_ethics_and_business_conduct.pdf
2/43/7
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LeidosWherever we do business, we are committed to upholding the core values embodied in this Code, which are influenced by, and reflect a respect for, human dignity and fundamental human rights. Leidos has implemented policies and practices, from which the concepts in this Code are generally derived, that support our commitment to protect and advance human dignity and human rights in our business practices.
https://www.leidos.com/sites/default/files/responsive/code-of-conduct/CodeOfConduct.pdf
2/43/7
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Lexis Nexus (Reed Elselvier)
"Principle 1: Businesses should support and respect the protection of internationally proclaimed human rights; and Principle 2: make sure that they are not complicit in human rights abuses." x
http://www.relx.com/corporateresponsibility/UNGlobalCompact/AboutUNGC/Pages/Home.aspx
2/43/7
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Lexmark"Lexmark upholds and respects international human rights standards as reflected in The Universal Declaration of Human Rights, the United Nations Global Compact, the United Nations Guiding Principles on Business and Human Rights, the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work (ILO) and the Organisation for Economic Co-operation and Development for Multinational Enterprises (OECD). Our support for these standards/principles is embedded in our Code of Business Conduct, our position on labor relations and our employment practices. All of our business operations as well as partner and supplier relationships are guided by these principles. We inspect for compliance through our management processes including operations reviews, risk management and internal audit"x
http://csr.lexmark.com/policy-human-rights.html
2/43/7
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Lockheed Martin - Information Systems & Global Solutions
"We will report periodically on our progress in upholding this policy and assess regularly whether changes are needed to ensure that we keep our commitment to good corporate citizenship and respect for human rights."
http://www.lockheedmartin.com/content/dam/lockheed/data/corporate/documents/ethics/cps-021.pdf
2/33/7
No Comment http://www.newyorker.com/business/currency/the-tech-resistance-to-the-trump-refugee-ban
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Mantech International, Inc.
"Suppliers must refrain from violating the rights of others and address any adverse human rights impacts of their operations."
http://www.mantech.com/Documents/ManTech%20Supplier%20Code%20of%20Conduct.pdf
2/33/7
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MarriottThere is DUE DILIGENCE LANGUAGE!!x
https://www.starwoodhotels.com/Media/PDF/Corporate/Starwood_Human_Rights_Policy_Statement_Final_12.15.pdf
2/63/7
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Microsoft"Our Global Human Rights Statement is itself grounded in the United Nations Guiding Principles on Business and Human Rights, which establishes that in their work to respect human rights, companies “should avoid infringing on the rights of others and should address adverse human rights impacts with which they are involved.” This is now a global standard of conduct expected of all businesses."x
https://www.microsoft.com/en-us/about/corporate-responsibility/human-rights
2/3
3/2/2017 "I’m responding on behalf of Microsoft to your email and your concerns regarding the Jan. 27 US executive order on immigration. We would like to direct your attention to the following blog by Microsoft that addresses this issue. Microsoft issued the following statement on Jan. 29 in response to the executive order: “We believe the executive order is misguided and a fundamental step backwards. There are more effective ways to protect public safety without creating so much collateral damage to the country’s reputation and values.” Microsoft will continue to advocate strongly on this and other issues with the Administration and with Congress."
3/2/2017 "Thank you very much for your reply. We have followed Microsoft's public statements with interest, and we are also aware that Microsoft joined the State of Washington's lawsuit against the administration, which has effectively halted the implementation of controversial components of the EO. The questions in our February 3 email pertain to any processes Microsoft may have employed to evaluate the company's position as a contractor to the Department of Homeland Security. Specifically, we would like to understand if Microsoft considered whether the services and software it provided to DHS might create a risk of "complicity" in human rights abuses, by facilitating the enforcement of the Order. In other words, did Microsoft carry out any internal reviews to determine whether its relationship with DHS would link it to the implementation of the Executive Order?"
3/3/2017 "Thank you for the follow up note. There is nothing additional to share at this time."
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Morpho Detection, Inc.
"Safran defends the principles of the United Nations Global Compact concerning human rights, labor, environment and the fight against corruption."x
http://www.safran-group.com/commitments/our-ethical-principles/trade-compliance/united-nations-global-compact-0
2/33/7
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Motorola Solutions, Inc.
"Our Corporate Responsibility Business Principles are supported by our Corporate Responsibility Policy, Code of Business Conduct, our Environment, Health and Safety and Human Rights policies, and our Supplier Code of Conduct."
https://www.motorola.com/us/about/corporate-responsibility-business-conduct https://www.motorolasolutions.com/en_us/about/company-overview/corporate-responsibility/governance-and-policies/human-rights-policy.html
2/33/7
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Nestle "By upholding international human rights standards, and continuous and consistent application of our own policies, which are aligned with the UN Guiding Principles on Business and Human Rights, Nestlé can make a positive impact on all our stakeholders."x
www.nestle.com/csv/human-rights-compliance/human-rights
2/33/7
3/7 "I think there may be some confusion- to our knowledge, we are not an important contractor to DHS. We have shared the questions with our colleagues in Switzerland, so that they can get in touch directly with any feedback." ... To which NomoGaia repolied: "Thanks so much for your reply. It came as a surprise to me as well, but Nestle is listed as a TSA contractor on 9 separate contracts for the 2016 year. Specifically, the contractor is Nestle Waters North America Holdings Inc (it lists its parent company as Nestle S.A)." NomoGaia followed up on 3/16 and received no response.
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Northrop Grumman Information Systems
"Company policies, practices and procedures reflect a strong commitment to human rights as set forth in the Universal Declaration on Human Rights. This commitment extends beyond the work environment to the global communities where we live, work and serve."
www.northropgrumman.com/CorporateResponsibility/Pages/HumanRightsPolicy.aspx
2/33/7
3/7 telephone call; 3/10 "As a matter of company policy, we must respectfully decline to comment on policy matters."
No Answer http://www.newyorker.com/business/currency/the-tech-resistance-to-the-trump-refugee-ban
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PAEUNGC Principle 1: "• Businesses should support and respect the protection of internationally proclaimed human rights • Make sure that they are not complicit in human rights abuses"x
https://www.pae.com/sites/default/files/2015%20COP%20-%20Final.pdf
2/33/7
3/13 "We do not have public comment for the report, but assure your team as well as the UNGC that our commitment to human rights remains strong in the many ways we support the U.S. Government and other nations."
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PWCNone
www.pwc.com/gx/en/ethics-business-conduct/pdf/pwc-global-code-of-conduct-update.pdf
2/33/7
3/8 "Thank you, we will look into this."
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Radisson"Respectful of human rights, socially equitable and environmentally sustainable, Radisson works to meet social and economic responsibility."
https://www.radisson.com/offers/4299341
2/63/7
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Raytheon"Ethics and Conduct to underscore our commitment to protection of human rights in our global business activities" and separately, "around the world, we spread awareness among employees and suppliers of potential human rights issues that may arise in some locations"
www.raytheon.com/rtnwcm/groups/public/documents/content/CA_transparency_supply_chain.pdf
2/33/7
No comment http://www.newyorker.com/business/currency/the-tech-resistance-to-the-trump-refugee-ban
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Red River Computer Company
None2/63/7
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Ricoh Corporationwe recognize respect for humanhuman rightsrights as the basis of our social responsibility and will continue to fulfill our duties to protect and promote humanhuman ri
http://www.ricoh.com/csr/human_rights/
2/63/7
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Science Applications International Corp. – $249 million
SAIC recognizes that we have a corporate responsibility to respect human rights in the operation of our business.
http://investors.saic.com/sites/saic.investorhq.businesswire.com/files/doc_library/file/Code_of_Conduct_Oct2016.pdf
2/33/7
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Sentrillionnone2/33/7
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Sharp ElectronicsThe Sharp Group respects fundamental human rights 
http://www.sharp-world.com/corporate/eco/ssr/hr/human_rights/approach/
2/33/7
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Sprint"As a leading global communications company, Sprint is committed to conducting business with integrity and complying responsibly with all applicable laws. We acknowledge and respect the broad principles aimed at promoting and protecting human rights as outlined in the Universal Declaration of Human Rights. We seek practical ways of applying these principles by focusing on our customers, enriching the workplace, engaging our suppliers, and strengthening the communities in which we do business."
goodworks.sprint.com/file_download.cfm?section_id=85
2/63/7
3/7 "This is the first I have seen of this. I have not received any previous communication. We will review."
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T-MobileNone but boasts of being "world's most ethical company"2/63/7
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UNISYS"Basic human rights should always be respected."
http://assets.unisys.com/Documents/Global/Misc/Code_of_Ethics.pdf
2/33/7
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UPSUPS supports the protection of human rights, p. 34 Code of Conduct
https://www.ups.com/media/en/code_bus_conduct.pdf
2/33/7
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Vencore, Inc.none2/33/7
55
VerizonWe respect the broad principles in the UN Universal Declaration of Human Rights,
http://www.verizon.com/about/sites/default/files/Verizon_Human_Rights_Statement.pdf
2/63/7
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VF Imagewear"All our significant investment agreements and contracts include human rights clauses or undergo human rights screening, as defined in our Global Compliance Program."x
https://business-humanrights.org/sites/default/files/VF%20Corporation_Know%20the%20Chain_Engagement%20questions.pdf
2/33/7
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Wildflower International
none2/3
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XeroxCommits to respect human rights
https://www.xerox.com/en-us/about/corporate-citizenship/human-rights
2/3
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